Exmark Manufacturing Co., Inc. v. Briggs & Stratton Power Group, LLC

Exmark sued Briggs & Stratton for infringement of a patent directed to a lawn mower having improved flow control baffles. .The court entered summary judgment that claim 1 was not invalid because the claim survived multiple reexaminations involving the same prior art and denied summary judgment of indefiniteness with respect to claim 1. A jury found that Briggs willfully infringed and awarded $24,280,330 in compensatory damages, which the court doubled as enhanced damages for willful infringement. The Federal Circuit vacated in part. The district court erred by determining invalidity solely on the fact that claim 1 survived multiple reexaminations; erred in denying a new trial on damages because Exmark’s damages expert failed to provide an adequate explanation for a 5% royalty rate for the patented feature relative to other conventional features of the accused products; and abused its discretion by limiting the evidence relevant to damages to prior art that had been commercialized, The district court's willfulness ruling did not comport with the Supreme Court’s 2016 decision in Halo Electronics, mandating that willfulness is to be determined by the jury regardless of whether Briggs’ defenses were objectively reasonable. The Federal Circuit affirmed the denial of summary judgment that claim 1 is indefinite and denial of Briggs’ laches defense. View "Exmark Manufacturing Co., Inc. v. Briggs & Stratton Power Group, LLC" on Justia Law